This document is available in three formats: this web page (for browsing content),
PDF (comparable to original
document formatting), and
WordPerfect.
To view the PDF you will need Acrobat Reader, which may be downloaded from the Adobe site. For an official signed copy, please contact the
Antitrust Documents Group.

DECLARATION OF REBEKAH J. FRENCH IN SUPPORT OF
PLAINTIFF'S MOTION FOR CLARIFICATION

My name is Rebekah J. French. I am a lawyer for the United States in the
above-captioned litigation.
I have had primary responsibility for responding to Defendants' discovery
demands in this case, and for complying with the Court's May 9, 2000, Memorandum and Order
("May 9 Order"). I submit this declaration in support of the United States' Motion for
Clarification of the May 9 Order.

I have personal knowledge of the following facts, unless otherwise noted, and could and
would testify competently thereto if called upon to do so.

After receiving the Court's May 9 Order, I instituted a search for CID materials
submitted
in response to the CIDs produced to American in response to Request No. 24 of American's
Second Set of Document Requests. Unlike previous searches conducted in this case, I did not
limit my selection of responsive CID materials to those materials which members of trial staff
had
used or intended to use in connection with this case. My search therefore resulted in the
discovery of many documents which had never been seen by members of the trial staff, much
less
used in connection with this case.

I was assisted in my search by two attorneys, and numerous paralegals assisted in the
bates-labeling and copying of the CID materials. Our only contact with the copies of materials
produced by ASTA in response to CID No. 12482 ("ASTA CID materials") resulted from our
efforts to comply with the Court's May 9 Order. Other than those persons who assisted me in
this search, no member of the trial staff has reviewed the ASTA CID materials in connection
with
this case.

I sent the ASTA CID materials to ASTA on May 20, 2000, along with a copy of the
Court's May 9 Order and September 14, 1999, Protective Order Governing Confidential
Information.

On June 6, 2000, I received a letter from ASTA's general counsel, Burton J. Rubin,
informing me that ASTA did not consent to the disclosure of the ASTA CID materials to
defendants, and would rely on the statutory prohibition against disclosure of this material.

I declare under penalty of perjury under the laws of the United States that the foregoing
is
true and correct to the best of my knowledge, information and belief. Executed this 23rd day of
June, 2000.